Eye on Economic Crime: Key takeaways from the UK Serious Fraud Office's Business Plan 2026-27

The UK Serious Fraud Office ("SFO") has released its Business Plan for 2026-27 (the "Plan"), outlining the strategy to combat serious fraud, bribery, and corruption at the mid-point of its five-year strategy. The Plan is outlined by Interim Director Graham McNulty, following the retirement of former Director Nick Ephgrave, highlighting that focus will remain on intelligence-led investigations and leveraging of technology as the SFO is backed by £8.3 million of additional funding.

This legal update frames the key changes to the SFO's Business Plan, the evolving threat landscape, and what businesses should be alert to.

1. Technology, Automation, and AI: The SFO will launch a new artificial intelligence (“AI”) roadmap, implement its first case management system, and use technology to speed up and enhance intelligence opportunities and analysis. In capitalising on the development of technology and AI tools, the SFO is presented with the opportunity to navigate their intelligence analysis through proactive tracking of suspects and suspicious activity. The SFO will mainstream the use of Technology Assisted Review to increase its efficiency, and automation will be used to expedite translation and transcription. Companies should ensure that their compliance and legal teams are adept at handling internal investigations effectively, and that they are exploring similar technology solutions to ensure they are up to pace with those expected to be adopted by the SFO.
2. Proactivity and Innovation: The SFO is delivering the 2026 Disclosure Improvement Plan to strengthen its approach to combatting crime, as well as its prevention programme to provide corporates with the tools and incentives to prevent bribery and corruption. Through investment, the SFO intends to further improve its organisational security and resilience, as well as using proactive intelligence to increase investigation sourcing, speed, and precision. The SFO is aiming at developing innovative routes to trace, secure, and recover the proceeds of crime. With a focus on speed and efficiency, the SFO are expected to conduct faster-moving, more creative investigations as well as adjusting their focus to prevention. Companies have an opportunity to engage proactively with the SFO's prevention programme to demonstrate a genuine commitment to preventing economic crime. Ensuring comprehensive and effectively implemented compliance programs to prevent fraud, bribery, and corruption is crucial for businesses, particularly in light of the new failure to prevent fraud offence.  
3. Crypto Assets: The SFO is concerned that a sophisticated knowledge of money laundering is no longer necessary, as the speed and global reach of crypto assets enable criminals to hide proceeds of crime with ease. In response to this threat, the SFO is developing and maximising crypto asset investigation capabilities. Companies should review their anti-money laundering programs and consider their exposure to crypto assets and digital asset transactions.
4. Digital Forensics: For its digital forensic activities, the SFO is aiming to progress towards UKAS accreditation. The SFO intends to scope its future e-Discovery needs in order to maximise the efficiency of its evidence review. Companies should adapt to heightened expectations regarding document management, preservation, and production, to be prepared for the SFO's digital forensics developments and potentially wide ranging disclosure requests.
5. International Cooperation: The SFO (together with its counterparts in Switzerland and France) will host the International Anti-Corruption Prosecutorial Taskforce Economic Crime Conference in May 2026. The Plan highlights the SFO's commitment to international collaboration, by reference to its initiatives including the taskforce with France's Parquet National Financier and the Office of the Attorney General of Switzerland which we covered in our April 2025 Legal Update. The Plan further outlines a commitment from the SFO to respond to the Financial Action Task Force inspection of the United Kingdom. As cross-border enforcement cooperation intensifies, companies with an international presence should take note that alignment between regulatory approaches across jurisdictions is likely to increase.
6. Fisher Report: The first part of the report by Jonathan Fisher KC ("Fisher Report"), titled "Fraud in the Digital Age" was submitted to the Government in November 2024 and was published by the Home Office in March 2025. It contains 45 recommendations addressing the criminal disclosure regime. Part 2 of the Fisher Report focuses on the challenges facing law enforcement and prosecutors in detecting, investigating, and prosecuting fraud offences in England and Wales. The Government is expected to publish this second part and its full response to the Fisher review in the next few months. The SFO has been actively engaged with the Fisher Review. Disclosure reform is evidently a key priority for the SFO as reflected in this latest Business Plan. The relevance of disclosure reform to the SFO has been recently underscored by the collapse of the London Mining prosecution in February 2026, where nearly 600,000 items were missed by the SFO's legacy e-discovery software, triggering a review of numerous other cases. The SFO's former Director Nick Ephgrave has been a vocal supporter of proposals for whistleblower incentivisation, which aligns closely with one of the key themes of Part 2. Disclosure reform is evidently a key priority. The Plan outlines a commitment from the SFO to lead strands of the Government's response to the Fisher Report.  
7. Office Relocation and Internal Strategy: The SFO will relocate to new offices in Canary Wharf, to enable modern and collaborative ways of working. This is supplemented by a focus on internal culture, leadership development opportunities, and the creation of a new career development framework for in-house opportunities. The attraction of new, highly skilled talent in conjunction with the office move will enable the SFO to work "shoulder to shoulder" with its regulatory partners. This is intended to reinforce the shared commitment and facilitate closer working relationships between the SFO and other regulatory bodies. Companies should be aware that career development, new recruits, and closer proximity may lead to more effective and collaborative regulatory action.

The Plan signals a clear intent from the SFO to deepen its use of technology to underpin its focus on innovation, efficiency, and proactive combat of financial crime.

We are closely monitoring the SFO's activity and their potential implications on an ongoing basis, in order to ensure we are in a position to effectively advise companies in all sectors. If you have any questions, please get in touch with the authors, or your usual Mayer Brown contact.